Comments and annotations regarding the ONJN draft legislative entitled “Minimum technical conditions for checking the means of play”

Monday, 25 November 2019

 

Part 2

By Radu BOLOCAN, General Manager of BBSC Communications

www.bbsc.ro

Radu Bolocan – B.B.S.C. Communication Systems

As already known by all interested parties and, at the same time, involved in the Romanian gambling industry, on July 22, 2019, ONJN notified to the European Commission the technical regulation document entitled “Minimum technical conditions for checking the gaming means”, respectively its latest version, version posted on the site www.onjn.gov.ro on June 14, 2019.

 

(continuation)

To continue with the previous article, in which some requirements regarding the type of technical control exercised by type approval were presented, this time we will refer to the specific requirements “software random number generator (RNG)“, requirements provided in the draft ONJN technical norm at pt. 12, section 2, chapter II.

For the beginning, we must remind, very briefly, that the software (pseudo) random number generator represents the “center of gravity” of the game program (software) installed on the respective gaming machine.

The integrity, correctness and proper functioning of an RNG are the ones that influence the following:

– firstly, the compliance with the legal requirements stipulated in GEO 77, art.5, paragraph (2), where the necessity of the existence of the “random number generator that determines the results of the games”, included in the “gambling software” is explicitly defined;

– the belief that the means of play have not been manipulated.

 

In short, the software random number generator (RNG), as its name implies, generates automatically, sequentially and on a statistical basis, a series of random numbers, which are dependent on fixed numbers called “seeds“.

Predicting the next number to be generated by an RNG is practically impossible because it would require studying all the previous results -the numbers generated- (and which are counted in hundreds of millions or even billions), which practically cannot be done in such a short period of time in the location where the gaming machine is placed.

Based on the random number sequence generated by the RNG, all the winnings offered (randomly) by the means of play are subsequently determined.

RNG testing is a complex and relatively laborious operation and it mainly refers to verifying the compliance with all the requirements imposed by a specialized referent (standard, technical norm, etc.), by applying statistical tests recognized by a mixed team of specialists (usually software, mathematicians/statisticians, physicists, etc.), members of a specialized testing laboratory.

For the purpose of assessing the conformity of the RNG incorporated in the software installed on the gaming machine, taking into account the number, complexity and duration of the tests necessary to be carried out and for which an ISO 17025 accredited test laboratory, specialized for this purpose, is required, at the proposal of BBSC Communications, the National Gambling Office – ONJN, strictly following the fulfillment of its objectives assumed and stipulated in the draft norm, especially in relation to ensuring competition in the gambling market, as well as the safe operation of the means of gambling on the territory of Romania, it was agreed that these RNG tests could also be performed in other specialized laboratories, independent and ISO 17025 accredited, and the acceptance and results of these RNG tests should be provided in the test reports that will be incorporated in the technical documentation that will be the basis of the process of obtaining the type approval for the means of gambling submitted to the approval, before being placed on the market and evaluated by the conformity assessment bodies and licensed class II by the ONJN.

The solution proposed by BBSC Communications is in accordance with the other specialized tests (egg. those related to immunity to electromagnetic fields and electrostatic discharges and other external influences) provided in the draft norm in point 8, section 2, chapter II.

The significant advantages that result from the proposed split could be, mainly, the following:

  • decreasing of the total costs generated by obtaining type approvals due to the fact that a person who applies for type approvals for more equipment (means of play) could use the documents resulting from the testing of an RNG, on several different means of play, but which use the same identical RNG;
  • reducing the total costs generated by obtaining type approvals due to a more competitive environment in terms of the offer existing in the market of the specific services provided;
  • shortening the time required to obtain type approvals from the conformity assessment bodies licensed by ONJN using the documents issued by other independent, specialized and ISO 17025 accredited testing laboratories, regarding identical RNGs or by parallel conducting, in within the two entities, of the specific activities;
  • real and concrete chances of being able to cover all the necessary to obtain the new type approvals, within a limited time period and strictly imposed by the future ONJN technical norm that will enter into force, by increasing the number of conformity assessment bodies available in the market, which will be able to carry out more quickly the specific and necessary activities for type approvals;

 

(to be continued)

Author: Editor

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